Heirs of Aida Pineda vs. Office of the President

Section 78 of the Indigenous Peoples' Rights Act expressly excludes the City of Baguio from the Act's application and leaves the determination of land rights there to its own charter, recognizing as valid only prior land rights and titles recognized or acquired through any judicial, administrative, or other process before the Act's effectivity; a Certificate of Ancestral Land Claim, by itself, is not such a recognized prior land right or title and confers no ownership over the land covered.

Republic Act No. 8371, the Indigenous Peoples' Rights Act of 1997, was signed into law on October 29, 1997, and Section 78 thereof carves out the City of Baguio from its operation, providing that the City shall remain governed by its own charter and that lands proclaimed as part of its townsite reservation shall remain as such until otherwise reclassified by appropriate legislation. Prior to the Act, the Department of Environment and Natural Resources issued Special Order No. 31, series of 1990, creating a Special Task Force on Ancestral Land Claims to receive, identify, evaluate, and delineate claims for ancestral lands in the Cordillera Administrative Region and, after processing, to issue appropriate land titles, with the paperwork completed in advance so that titles could be issued once the enabling law was enacted. The Baguio Townsite Reservation had been established on April 12, 1912, and Civil Reservation Case No. 1, GLRO Reservation Record No. 211, was filed with the Court of Land Registration in 1912 to determine which lands within it were public and which were private. The parties are the heirs of two claimants to the same Baguio City parcels — Aida Pineda, who obtained Certificates of Ancestral Land Claim under Special Order No. 31, and Teofilo Pilando, Sr., whose heirs trace a prior right of possession and occupation.

In 1991, Aida Pineda filed with the Department of Environment and Natural Resources an application for an ancestral land claim over a parcel in Baguio City with a total area of 49,645 square meters. The application rested on Department of Environment and Natural Resources Special Order No. 31, series of 1990, which created a Special Task Force on Ancestral Land Claims "to receive identify, evaluate and delineate claims for ancestral lands in the Cordillera Administrative Region, and after processing to issue appropriate land titles." From November 12 to 19, 1991, Pineda caused the survey of the land, which the Regional Surveys Division of the Department of Environment and Natural Resources approved on March 31, 1992. Survey Plan SWO CAR-000065 described the area claimed as a "portion of Lot No. 1, PSU-223647, as surveyed for Teofilo Pilando covered by Civil Res. Case 1, GLRO Rec. No. 211."

On June 24, 1993, the Department of Environment and Natural Resources, upon the recommendation of the Special Task Force, issued four Certificates of Ancestral Land Claim — Bg-0032, Bg-0033, Bg-0034, and Bg-0035 — covering 61,673 square meters of land at Residential Section "J", Loakan, Baguio City, in favor of Pineda.

On August 22, 1996, the Heirs of Teofilo Pilando, Sr. filed a Petition for Annulment of the Certificates of Ancestral Land Claim before the Department of Environment and Natural Resources. They claimed a prior right traceable to Teofilo Pilando, Sr., a member of the Kankanaey tribe, who purchased a 90,904-square-meter parcel from Talin Simsim of the Ibaloi tribe in 1956 or 1957 and thereafter introduced improvements on it. Pilando, in anticipation of securing a Torrens title, caused the survey of the land, which the Bureau of Lands approved in SWO-129547 on October 13, 1966, and he had declared the land for tax purposes since 1967. On these premises, the Heirs of Pilando asserted that their predecessor-in-interest acquired ipso jure title and possession of the land, and that their more than thirty years of possession had converted the land into private property. In their Answer, the Heirs of Pineda asserted that Pilando's claim was fraudulent.

The Department of Environment and Natural Resources resolved the controversy in its February 27, 2007 Decision by ordering the recall of the Certificates of Ancestral Land Claim issued in favor of Pineda and the segregation of the claim of the Heirs of Pilando, explaining that the recommendations of the Special Task Force could not be held binding because its actions were merely in anticipation of the Indigenous Peoples' Rights Act, the same Act that expressly excluded Baguio City from its operation, and that the Heirs of Pilando had clearly established a prior right as long-time occupants of public land. The Office of the President affirmed on March 30, 2011, adding that the Heirs of Pilando and their predecessors-in-interest were deemed to have acquired, by operation of law, a right to a government grant over the land given their open, continuous, exclusive, and notorious possession and occupation, and that the certificates issued to the Heirs of Pineda were void because the Special Task Force had no authority to issue them.

On review, the Supreme Court found that, aside from their Certificates of Ancestral Land Claim, the petitioners were unable to establish the basis of their rights of possession and ownership over the lots involved, having failed to establish how their predecessors-in-interest acquired the lots and how long they and their predecessors-in-interest had been in possession of the same. The Court likewise noted that the lots applied for in 1991 covered a total area of only 49,645 square meters, yet the Certificates of Ancestral Land Claim issued were inexplicably expanded to 61,673 square meters.

• Contrary to City Government of Baguio vs. Masweng: Petitioners claimed that the Court of Appeals ruled contrary to City Government of Baguio vs. Atty. Masweng, which held that Baguio City's exemption from the provisions of the Indigenous Peoples' Rights Act cannot be deduced from the Act itself.
• Disregard of Native Title: Petitioners claimed that the Court of Appeals violated the Constitution in disregarding their native title over the ancestral land despite sufficient evidence of full possession and ownership of the land as far back as memory reaches.
• Vested Right Over the Ancestral Land: Petitioners insisted that they have a vested right over the ancestral land, reinforced by the Indigenous Peoples' Rights Act and the Baguio City Charter, and that respondents have neither title nor any pending land title application.
• Baguio City Not Exempt from the IPRA (Reply): Petitioners insisted in their Reply that Baguio City is not exempt from the coverage of the Indigenous Peoples' Rights Act, and that they proved their ownership and title over the land.

• Finality of the Office of the President's Decision: Private respondents claimed that the Court of Appeals did not err in affirming the Office of the President's Decision because that Decision was already final and executory, and it merely affirmed the Department of Environment and Natural Resources' Decision issued in the exercise of its jurisdiction.
• Substantial Evidence and Conformity with Law: Private respondents further claimed that the Department of Environment and Natural Resources' Decision is supported by substantial evidence, and in accord with law and jurisprudence.
• Denial of Due Process and Want of Authority: Private respondents argued that they were not afforded due process in the issuance of the Certificates of Ancestral Land Claim, and that these certificates are void for having been issued without authority of law.
• Absence of Prior Land Rights and Titles: Private respondents claimed that City Government of Baguio rejected ancestral land claims over parcels of land in Baguio City for lack of prior land rights and titles recognized through any judicial, administrative, or other processes before the effectivity of the Indigenous Peoples' Rights Act.
• Superiority of Open, Continuous, and Exclusive Possession: Private respondents claimed that petitioners' alleged ancestral land claim under the Indigenous Peoples' Rights Act cannot prevail over their open, continuous, and exclusive possession and occupation in the concept of an owner.
• Absence of Grave Abuse of Discretion: Private respondents claimed that petitioners failed to show where the Office of the President and the Department of Environment and Natural Resources gravely abused their discretion in ruling against petitioners.

• Recall of the Certificates of Ancestral Land Claim: Whether the Court of Appeals erred in affirming the decisions of the Department of Environment and Natural Resources and the Office of the President recalling the Certificates of Ancestral Land Claim issued in favor of petitioners.

• Recall of the Certificates of Ancestral Land Claim: No. The Petition was denied. Section 78 of the Indigenous Peoples' Rights Act expressly excludes the City of Baguio from the application of its provisions, and a Certificate of Ancestral Land Claim, by itself, does not qualify as a valid prior land right and title over ancestral land.

• Recall of the Certificates of Ancestral Land Claim: Section 78 of the Indigenous Peoples' Rights Act of 1997 expressly excludes the City of Baguio from the application of its provisions, providing that the City shall remain governed by its Charter, that all lands proclaimed as part of its townsite reservation shall remain as such until otherwise reclassified by appropriate legislation, and that prior land rights and titles recognized and/or acquired through any judicial, administrative, or other processes before the Act's effectivity shall remain valid. In Republic vs. National Commission on Indigenous Peoples, the Court construed this provision as mandating that (1) the City of Baguio shall not be subject to the provisions of the Act but shall still be governed by its own charter; (2) all lands previously proclaimed as part of the City's Townsite Reservation shall remain as such; (3) reclassification of properties within the Townsite Reservation may be made only through a law passed by Congress; (4) prior land rights and titles recognized and acquired through any judicial, administrative, or other process before the Act's effectivity shall remain valid; and (5) territories which became part of the City after the Act's effectivity are exempted. Thus, for properties part of the townsite reservation before the passage of the Act, no new Certificate of Ancestral Land Title or Certificate of Ancestral Domain Title may be issued by the National Commission on Indigenous Peoples, whose power to reclassify such lands is devoid of basis, that power being vested solely in Congress. The Court emphasized that Section 78 conclusively provides that the charter of Baguio City shall govern the determination of land rights within the City and not the Indigenous Peoples' Rights Act, a ruling echoed in City Government of Baguio vs. Atty. Masweng, which held that Baguio City is governed by its own charter although its exemption from the Act cannot ipso facto be deduced because the law concedes the validity of prior land rights recognized or acquired through any process before its effectivity. Despite giving primacy to the City's charter, Section 78 expressly recognizes as valid prior land rights and titles recognized or acquired through any judicial, administrative, or other processes before the Act's effectivity, and Section 56 of the same Act emphasizes recognition and respect of property rights within ancestral domains already existing or vested upon the Act's effectivity. Petitioners anchored their right on the Certificates of Ancestral Land Claim issued by the Department of Environment and Natural Resources pursuant to Special Order No. 31, series of 1990. In Philippine Economic Zone Authority vs. Borreta, where the private respondent invoked a Certificate of Ancestral Land Claim as basis for his claim over the land, the Court held that he was a mere applicant for the issuance of a certificate of ownership of ancestral land who had not acquired a vested right as owner so as to exclude the same from the areas under the Philippine Economic Zone Authority. In Philippines Economic Zone Authority vs. Carantes, the Court reiterated Borreta and enumerated the rights of holders of a Certificate of Ancestral Land Claim under Paragraph 1, Section 2, Article VII of DENR Department Administrative Order No. 02, Series of 1993 — the right to peacefully occupy and cultivate the land and utilize the natural resources therein subject to existing laws; the right of heirs to succeed to the claims; the right to exclude from the claim any other person who does not belong to the family or clan; and the right to utilize trees and other forest products inside the ancestral land subject to the rules and customary laws — holding that holders of a mere Certificate of Ancestral Land Claim possess no greater rights, that their right to possess is limited to occupation in relation to cultivation, and that nothing in Section 2 grants them the right to build permanent structures on ancestral lands, an act of ownership pertaining to one who has a recognized right by virtue of a Certificate of Ancestral Land Title. The records disclosed the same limited rights here, so the Certificates of Ancestral Land Claim did not give petitioners rights pertaining to ownership over the property. As explained by the Department of Environment and Natural Resources, the Special Task Force, pursuant to Special Order No. 31, series of 1990, was organized to start receiving and processing ancestral land claims including claims within the Baguio Townsite, and to complete the paperwork beforehand so that the corresponding titles could be issued as soon as the enabling law would be enacted. The Certificates of Ancestral Land Claim are not conclusive title over the land and were merely issued in anticipation of the passage of the Indigenous Peoples' Rights Act; petitioners still needed to convert them to Certificates of Ancestral Land Title pursuant to National Commission on Indigenous Peoples Administrative Order No. 2-02, whose Section 5 covers all ancestral land claims officially delineated under DENR Special Order No. 31 and No. 31-A, as amended, both series of 1990, with coverage in the Cordilleras. Petitioners, however, were unable to convert their Certificates of Ancestral Land Claim to Certificates of Ancestral Land Title. Petitioners' insistence on prior land rights under Section 78 and on native title over the lots was belatedly raised in the Petition, which invited the Court to evaluate the evidence and make its own factual conclusions. Under Rule 45, Section 1 of the Rules of Court, only questions of law may be raised in a petition for review on certiorari, and factual findings of the appellate courts are generally binding upon the Court, especially when supported by substantial evidence; parties must allege, prove, and substantiate that their case clearly falls under an exception. Petitioners failed to convince the Court of the need to review the factual findings of the Court of Appeals, especially since these conformed with the findings of both the Department of Environment and Natural Resources and the Office of the President; the matter of who between petitioners and respondents enjoyed a prior, more preeminent right over the lots is a factual matter not proper in a Rule 45 petition. Nonetheless, the Court ruled on petitioners' claim. In the 1909 case of Cariño vs. Insular Government, the United States Supreme Court ruled in favor of Cariño, who applied for ownership over land in Benguet he claimed to have occupied and tilled since time immemorial, affirming the validity of native title and holding that when, as far back as testimony or memory goes, land has been held by individuals under a claim of private ownership, it will be presumed to have been held in the same way from before the Spanish conquest and never to have been public land. Republic vs. National Commission on Indigenous Peoples explained the governing law giving validity to prior land rights and titles over lots claimed since time immemorial in Baguio City: Section 32 of Act No. 926 entitled native occupants and cultivators of unreserved, unappropriated agricultural public land to a free patent; Baguio City was incorporated on September 1, 1909, and the Baguio Townsite Reservation was established on April 12, 1912; Civil Reservation Case No. 1, GLRO Reservation Record No. 211, was filed in 1912 with the Court of Land Registration to resolve which lands were public and private; pursuant to Section 62 of Act No. 926, the Court of First Instance of Benguet issued a notice on July 22, 1915 requiring all persons claiming lots inside the Baguio Townsite Reservation to file within six months petitions for registration of their titles under Act No. 496; on November 13, 1922, the Court of First Instance held that all claims for private lands by persons who did not present them for registration within the period in Act No. 627 are barred forever; and on August 16, 1954, President Ramon Magsaysay issued Administrative Order No. 55, series of 1954, authorizing a committee to study the claims of inhabitants, under which 48 Igorot claimants originally filed claims and 285 others later filed additional claims, with the respondents in that case not among them. Since those respondents claimed possession since time immemorial, their predecessors were necessarily given notice of the reservation and should have filed their claims within the stated period, but no such claim was filed, and the lots were not shown to be part of any ancestral land prior to the effectivity of the Act; their rights were never recognized in any administrative or judicial proceedings prior to the Act's effectivity, rendering the Certificates of Ancestral Land Title and Certificates of Ancestral Domain Title issued to them void. Applying the same standard here, petitioners failed to establish that their rights over the properties were validly recognized in any administrative or judicial proceedings prior to the effectivity of the Indigenous Peoples' Rights Act; aside from their Certificates of Ancestral Land Claim, they were unable to establish the basis of their rights of possession and ownership, having failed to show how their predecessors-in-interest acquired the lots and how long they and their predecessors had been in possession. Moreover, aside from failing to prove that the lots were ancestral land, the lots they applied for in 1991 covered only a total area of 49,645 square meters, yet the Certificates of Ancestral Land Claim issued were inexplicably expanded to 61,673 square meters. In Presidential Decree No. 1271 Committee vs. De Guzman, the Court invalidated Transfer Certificates of Title with expanded areas of lots which were included in the titles only as a result of the subdivision of the lots covered by the original titles, or a resurvey of property, and compelled the courts to be more aware of the machinations used by unscrupulous parties to acquire and title lands in Baguio City.

• Section 78 of the Indigenous Peoples' Rights Act — Baguio City Exemption — Section 78 is a special provision mandating that (1) the City of Baguio shall not be subject to the provisions of the Act but shall still be governed by its own charter; (2) all lands previously proclaimed as part of the City's Townsite Reservation shall remain as such; (3) reclassification of properties within the Townsite Reservation may be made only through a law passed by Congress; (4) prior land rights and titles recognized and acquired through any judicial, administrative, or other process before the Act's effectivity shall remain valid; and (5) territories which became part of the City after the Act's effectivity are exempted. The Court applied the provision to hold that the determination of land rights within Baguio City is governed by its charter and not by the Indigenous Peoples' Rights Act, and that the National Commission on Indigenous Peoples is devoid of power to issue new Certificates of Ancestral Land Title or Certificates of Ancestral Domain Title over properties that formed part of the townsite reservation before the Act's passage.
• Certificate of Ancestral Land Claim Confers No Ownership — A Certificate of Ancestral Land Claim is not a conclusive title over land and is merely issued in anticipation of the passage of the Indigenous Peoples' Rights Act; it must still be converted into a Certificate of Ancestral Land Title under National Commission on Indigenous Peoples Administrative Order No. 2-02. A holder possesses no greater rights than those enumerated in Paragraph 1, Section 2, Article VII of DENR Department Administrative Order No. 02, Series of 1993: (a) the right to peacefully occupy and cultivate the land and utilize the natural resources therein, subject to existing laws, rules, and regulations; (b) the right of heirs to succeed to the claims, subject to existing rules and regulations; (c) the right to exclude from the claim any other person who does not belong to the family or clan; and (d) the right to utilize trees and other forest products inside the ancestral land, subject to the rules and customary laws. The right to possess is limited to occupation in relation to cultivation; the holder has no right to build permanent structures, an act of ownership pertaining to one who has a recognized right by virtue of a Certificate of Ancestral Land Title. Because the petitioners never converted their certificates, they acquired no ownership rights over the land.
• Native Title (Cariño Doctrine) — When, as far back as testimony or memory goes, land has been held by individuals under a claim of private ownership, it will be presumed to have been held in the same way from before the Spanish conquest and never to have been public land. The Court acknowledged this doctrine but held that the petitioners failed to establish that their rights over the properties were validly recognized in any administrative or judicial proceeding prior to the effectivity of the Indigenous Peoples' Rights Act, and that they failed to show how their predecessors-in-interest acquired the lots or how long they had possessed them.
• Prior Land Rights and Titles Under Section 78 — Section 78 saves only prior land rights and titles recognized or acquired through any judicial, administrative, or other process before the effectivity of the Indigenous Peoples' Rights Act, a recognition reinforced by Section 56 of the same Act, which respects property rights within ancestral domains already existing or vested upon the Act's effectivity. Where the claimants' predecessors were given notice of the Baguio Townsite Reservation and failed to file claims within the period fixed under Act No. 627, their rights were never recognized in any administrative or judicial proceeding prior to the Act's effectivity, and titles subsequently issued are void.
• Rule 45 Limits Review to Questions of Law — Under Rule 45, Section 1 of the Rules of Court, only questions of law may be raised in a petition for review on certiorari, and factual findings of the appellate courts are generally binding upon the Supreme Court, especially when supported by substantial evidence. The determination of who between contending claimants enjoys a prior, more preeminent right over land is a factual matter not proper in a Rule 45 petition, and a party inviting the Court to re-evaluate the evidence must show that the case falls clearly under an exception.
• Invalidity of Titles Covering Expanded Areas — Titles covering areas expanded beyond what was originally applied for or surveyed are invalid, as where Transfer Certificates of Title included additional lots merely as a result of subdivision or resurvey. The Court applied this principle to note that the petitioners applied in 1991 for only 49,645 square meters but were issued Certificates of Ancestral Land Claim covering 61,673 square meters.

• "Section 78 is a special provision in the IPRA which clearly mandates that (1) the City of Baguio shall not be subject to provisions of the IPRA but shall still be governed by its own charter; (2) all lands previously proclaimed as part of the City of Baguio's Townsite Reservation shall remain as such; (3) the re-classification of properties within the Townsite Reservation of the City of Baguio can only be made through a law passed by Congress; (4) prior land rights and titles recognized and acquired through any judicial, administrative or other process before the effectivity of the IPRA shall remain valid; and (5) territories which became part or the City of Baguio after effectivity of the IPRA are exempted." — This passage, quoted from Republic vs. National Commission on Indigenous Peoples, supplies the canonical five-part construction of Section 78 of the Indigenous Peoples' Rights Act and is the doctrinal anchor of the decision.
• "Respondents being holders of a mere CALC, their right to possess the subject land is limited to occupation in relation to cultivation. Unlike No. 1, Par. 1, Section 1, Article VII of the same DENR DAO, which expressly allows ancestral domain claimants to reside peacefully within the domain, nothing in Section 2 grants ancestral land claimants a similar right, much less the right to build permanent structures on ancestral lands — an act of ownership that pertains to one (1) who has a recognized right by virtue of a Certificate of Ancestral Land Title." — Quoted from Philippines Economic Zone Authority vs. Carantes, this passage defines the limited rights of a Certificate of Ancestral Land Claim holder and explains why such a certificate cannot support a claim of ownership.
• "It might, perhaps, be proper and sufficient to say that when, as far back as testimony or memory goes, the land has been held by individuals under a claim of private ownership, it will be presumed to have been held in the same way from before the Spanish conquest, and never to have been public land." — This is the classic formulation of the native title doctrine from Cariño vs. Insular Government, cited by the Court as the governing rule on prior land rights over lots claimed since time immemorial in Baguio City.
• "Here, petitioners failed to establish that their rights over the properties were validly recognized in any administrative or judicial proceedings prior to the effectivity of the Indigenous Peoples' Rights Act." — This sentence states the decisive application of Section 78's savings clause to the petitioners and is the ratio of the denial of the Petition.

• Republic vs. National Commission on Indigenous Peoples, G.R. No. 208480, September 25, 2019 [Acting C.J. Carpio, Second Division] — Controlling precedent. The Court adopted its five-part construction of Section 78 of the Indigenous Peoples' Rights Act and its explanation of the governing law on prior land rights in Baguio City, including the effect of the 1915 notice, the 1922 ruling of the Court of First Instance of Benguet barring unregistered claims, and Administrative Order No. 55, series of 1954.
• City Government of Baguio vs. Atty. Masweng, 597 Phil. 668 (2009) [Per J. Tinga, Second Division] — Followed and reconciled. The Court cited it for the proposition that Baguio City is governed by its own charter, while clarifying that its exemption from the Indigenous Peoples' Rights Act cannot ipso facto be deduced because the law concedes the validity of prior land rights recognized or acquired before its effectivity.
• Philippine Economic Zone Authority vs. Borreta, 519 Phil. 637 (2006) [Per J. Sandoval-Gutierrez, Second Division] — Followed. Cited for the ruling that a Certificate of Ancestral Land Claim holder is a mere applicant who has not acquired a vested right as owner.
• Philippines Economic Zone Authority vs. Carantes, 635 Phil. 541 (2010) [Per J. Villarama, Jr., Third Division] — Followed. Cited for the enumeration of the limited rights of Certificate of Ancestral Land Claim holders under DENR Department Administrative Order No. 02, Series of 1993, and for the ruling that such holders may not build permanent structures on ancestral lands.
• Cariño vs. Insular Government, 41 Phil. 935 (1909) [J. Holmes, United States Supreme Court] — Cited as the source of the native title doctrine, affirming the validity of title over land occupied and tilled since time immemorial and the presumption that land held under a claim of private ownership as far back as memory goes was never public land.
• Presidential Decree No. 1271 Committee vs. De Guzman, 801 Phil. 731 (2016) [Per J. Leonen, Second Division] — Cited. Used to support the invalidation of titles with expanded areas and to admonish courts to be more aware of machinations used by unscrupulous parties to acquire and title lands in Baguio City.
• Pascual vs. Burgos, 776 Phil. 167 (2016) [Per J. Leonen, Second Division] — Cited. Invoked for the rule that factual findings of the appellate courts are generally binding on the Supreme Court and for the requirement that a party show that its case falls under an exception before factual questions may be reviewed.
• Dela Cruz vs. National Police Commission, G.R. No. 215545, January 7, 2019 [Per J. Leonen, Third Division] — Cited alongside Pascual vs. Burgos for the rule on the binding character of factual findings and the exceptions permitting review of questions of fact.

• Section 78, Republic Act No. 8371 (Indigenous Peoples' Rights Act of 1997) — The Special Provision providing that the City of Baguio shall remain governed by its Charter, that lands proclaimed as part of its townsite reservation shall remain as such until otherwise reclassified by appropriate legislation, and that prior land rights and titles recognized and/or acquired through any judicial, administrative, or other processes before the Act's effectivity shall remain valid. The Court applied it to hold that Baguio City is excluded from the Act's operation and that the petitioners' Certificates of Ancestral Land Claim did not qualify as saved prior land rights or titles.
• Section 56, Republic Act No. 8371 — Cited for the Act's recognition and respect of property rights within ancestral domains already existing or vested upon the Act's effectivity, reinforcing the savings clause of Section 78.
• Paragraph 1, Section 2, Article VII, DENR Department Administrative Order No. 02, Series of 1993 — Enumerates the rights and responsibilities of ancestral land claimants: the right to peacefully occupy and cultivate the land and utilize natural resources therein subject to existing laws; the right of heirs to succeed to the claims; the right to exclude non-members of the family or clan; and the right to utilize trees and other forest products subject to the rules and customary laws. The Court used it to show that a Certificate of Ancestral Land Claim holder possesses no ownership rights and may not build permanent structures.
• Sections 3 and 5, National Commission on Indigenous Peoples Administrative Order No. 2-02 (Revised Guidelines for the Conversion of Certificate of Ancestral Domain/Land Claims to Certificate of Ancestral Domain/Land Titles Delineated Prior to Republic Act No. 8371) — Section 3 declares the policy of converting meritorious Certificates of Ancestral Domain Claim and Certificates of Ancestral Land Claim to Certificates of Ancestral Domain Title and Certificates of Ancestral Land Title without going through the process provided in the law, subject to review and validation; Section 5 covers all ancestral land claims officially delineated under DENR Special Order No. 31 and No. 31-A, as amended, both series of 1990, with coverage in the Cordilleras. The Court applied these provisions to hold that the petitioners still needed to convert their certificates and failed to do so.
• Section 1, Rule 45, Rules of Court — Limits a petition for review on certiorari to questions of law. The Court applied it to decline review of the factual findings of the Court of Appeals, the Department of Environment and Natural Resources, and the Office of the President on which claimant held the prior and more preeminent right.
• Section 32, Act No. 926 — The provision on free patents to native settlers, entitling a native occupant and cultivator of unreserved, unappropriated agricultural public land who has continuously occupied and cultivated it since August 1, 1898, or for three years immediately prior to that date and continuously since July 4, 1902, to a patent without compensation for a tract not exceeding sixteen hectares. Cited in the Court's discussion of the remedy afforded to indigenous cultural communities for prior land rights.
• Section 62, Act No. 926 — Authorizes the Chief of the Bureau of Public Lands, with the approval of the Secretary of the Interior, to notify the Court of Land Registration that lands have been reserved as a town site and that all private lands or interests therein must be brought within the operation of the Land Registration Act. Cited to explain the process by which the Baguio Townsite Reservation was established and private claims required to be registered.
• Act No. 627 — Requires landowners affected by the declaration of military reservations to register their titles within the period stated in the Land Registration Act, failing which their land rights are considered barred. Cited in connection with the July 22, 1915 notice requiring claims within the Baguio Townsite Reservation to be registered within six months.
• Act No. 496 (Land Registration Act) — The registration law under which private lands within the Baguio Townsite Reservation were required to be registered, as provided by Act No. 926. Cited in the Court's account of the proceedings in Civil Reservation Case No. 1.
• Administrative Order No. 55, Series of 1954 — Issued by President Ramon Magsaysay, it authorized the formation of a committee to study the claims of inhabitants of the Baguio Townsite Reservation with a view to determining whether it was in the public interest to segregate their landholdings from the reservation and open them to disposition under the Public Land Act. Cited to show that the respondents in the governing precedent were not among the original or additional claimants.

Lazaro-Javier, M. Lopez, J. Lopez, and Kho, Jr., JJ., concur.